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The Article ‘The Golden Triangle in the Indian Constitution: Articles 14, 19, and 21’ by Pallavi Panchwal primarily examines the golden triangle, its applicability, and its importance under the Indian Constitution. The idea of the author is to be well-acquainted with the golden triangle in our Indian Constitution with the help of various relevant case laws. The article also contains brief information about the Indian Constitution and its various topics. In the concluding part, the author justifies why there is a differentiation between the Constitution of India and the Constitutions of the world and thus appreciates the features of the Indian Constitution.
A Brief Introduction: Indian Constitution
Indian constitution is the lengthiest constitution in the world, consisting of a Preamble, 448 Articles which have been carved into 25 parts, and 12 schedules. It is India’s supreme law and establishes a federal system within India. Its Preamble declares to constitute the country as a sovereign, socialistic, secular, democratic, republic; Furthermore, it assures the citizens of providing justice, equality, and liberty. In addition, it seeks to promote fraternity among them.
The anatomy of this supreme law of the Indian sub-continent has been carried out with such elegance that it contains almost every topic related to citizenship, fundamental rights, directive principles of state policy, provisions of state or provisions of centre or centre and state relationship, etc. which have been enshrined within the provisions in the constitution.
Fundamental Rights in India
Fundamental rights are the backbone of the country. These are essential for safeguarding the people’s interests. Part III of the Indian constitution has been dedicated to fundamental rights. Earlier, seven fundamental rights were mentioned in the constitution, but later Right to property was eliminated. Currently, the Right to Freedom, the Right to Equality, Cultural and Educational Rights, the Right to Constitutional Remedies, and the Right Against Exploitation are six fundamental rights provided in the Indian Constitution.
Article 12 to Article 35 have been enshrined in Part III of the Indian Constitution which encompasses the prohibition of discrimination on the grounds of religion, race, caste, sex, or place of birth; equality of opportunity in matters of public employment; invalidation of untouchability, invalidation of titles; protection of certain rights regarding freedom of speech, etc., protection in respect of conviction for offences, protection of life and personal liberty, validation of certain Acts and Regulations, cultural and educational rights, etc.
The Golden Triangle
Golden Triangle is a concept related to fundamental rights. The provisions of Article 14, Article 19, and Article 21, together under the Indian constitution, are known as the Golden triangle. All these articles are essential for understanding fundamental rights and the basic structure of the Constitution. They are essential ingredients for the betterment and quality of every individual’s life.
i) Article 14
It carries two concepts within it–
- Equality before law
- Equal protection of laws.
It assures equality for all individuals. It is a fundamental right for citizens and for people who are not citizens of our territory. The basic concept of liberalism is to treat every individual equally, and Article 14 ensures the same. All persons should be treated equally, whether poor or rich, male or female, upper caste or lower caste.
ii) Article 19
- This article guarantees six fundamental freedoms to the citizens of India. These fundamental freedoms are the natural and basic freedoms built in the status of a citizen with certain reasonable restrictions. It also tells the general exceptions, to which the validity of sub-clauses within clause (1) of Article 19 may not extend.
iii) Article 21
- It declares that no person shall be underprivileged in his life or personal liberty. In the case of AK Gopalan v. State of Madras the supreme court held that the state can deprive a person of the rights available in Article 21, based on law; Whereas in Maneka Gandhi v. Union of Indiathe supreme court overruled this judgment of the Gopalan Case. The court further held that a person could be deprived by law on the condition that the procedure prescribed by that law is reasonable, fair, and just.
This trio of articles is considered to be triangles because they are connected together with each other and are termed Golden because they have the utmost importance in protecting the rights of people and preventing arbitrariness within the government. It provides protection to citizens of India from the encroachment of their rights.
Applicability of The Golden Triangle
The golden triangle provides full shielding to individuals from any infringement upon their rights. The Apex court of India has said that while interpreting Articles 14, 19, and 21, the court must mix the provisions together and interpret them as a whole.
In the case of Kesavananda Bharati v. State Of Kerala, the honourable Supreme court of India observed that, whether it is center or state, the fundamental rights of the citizens shall not have encroached. It means that centre and state have some limitations that are discussed and elaborated in the Indian constitution.
The landmark judgment regarding the interconnection between these articles came in the case of Maneka Gandhi v. Union of India, and it brought a huge transformation in the Jurisprudence of the Golden Triangle of the Indian constitution. The court held that a law that sets a procedure for depriving a person of his/her personal liberty has to satisfy the necessity of both Articles 14 and 19. The procedure must be just and fair and must meet the demand of reasonableness.
The court observed that this case not only deals with Article 21 (right to life and personal liberty) but here, Article 14 (right to equality) and Article 19 (right to freedom) are discussed in great length. The court looked into matters not only influencing Article 21 but also Articles 14 and 19 as well. The judgment was one of the landmarks among the cases relating to the breach of certain fundamental rights, mainly, Articles 14, 19, and 21.
The trinity of Articles 14, 19, and 21 together seeks to grant complete protection to an individual from infringement of their basic rights, which every human is entitled to. The Golden Triangle present in part III of the Constitution of India plays an important role in the judiciary and affects our day-to-day life. The purpose is to protect the basic rights of an individual. The Drafters of the Indian Constitution framed the constitution in such a way that it must neither make any mandatory provision regarding various rights for the citizens nor make any citizen free from certain fundamental duties that must be followed by every citizen of India.
Constitution also provides certain other rights and duties towards the citizen, which are included in Part IV of the Constitution, known as ‘Directive Principles of State policy.’ One of the benefits of the Indian constitution is that it does not restrict a person from exercising his or her basic rights, nor does it grant a person complete liberty so that he can use or breach these rights for himself or against society. This differentiates our Constitution from other constitutions in the world.
 1950 AIR 27, 1950 SCR 88
 AIR 1978 SC 597; (1978) 1 SCC 248
 (1973) 4 SCC 225; AIR 1973 SC 1461
 AIR 1978 SC 597; (1978) 1 SCC 248